Investor Portal

Privacy Policy

Privacy Policy & Statement

Privacy Statement

IPG Funds Management Pty Ltd (IPG FM) is part of the IP Generation Group of Companies (IPG Group or Group). The IPG Group includes IP Generation Holdings Pty Ltd (IPGH), IPG FM and each of their Subsidiaries (Group members) from time to time. IP Generation was established in 2018 to act as the holding entity for a property funds management business.

IPG FM is a wholly owned subsidiary of IPGH and holds an Australian Financial Services License (AFSL 476564). IPG FM is authorised under its AFSL to offer unregistered managed investment schemes (Schemes) to Wholesale Investors as defined in the Corporations Act 2001. IPG FM, and other relevant Group members, have outsourced their corporate administrative activities to their parent IPGH via a Business Services Agreement. In their capacity as Trustee for Schemes, Group Members may outsource management of the Schemes to IPGH under an Investment Management Deed. IPG FM has entered an Investment Management Deed with IPGH to outsource all investment management services in relation to Schemes for which it acts as Trustee.

The IPG Group Charter governs the modus operandi of the IPG Group. The IPG Governance framework sets out the roles and responsibilities of the various Group members and documents the relationship between them.

We are committed to safeguard the privacy of the personal Information we collect in accordance with the Australian Privacy Act 1988 and associated privacy principles.

What kind of personal information is collected and held?

IPG FM, and other Group members if applicable, are required to collect, hold and use personal information in the course of their normal business activities. Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

The types of personal information we collect include:

Your name, home address, date of birth, contact details (including your address, phone numbers and emails, whether personal or work related. Other identification verification information, including photographic information from documents like your passport, driver’s licence, pension card, citizenship certificate, tax notice assessment, Medicare card and utilities notices. Financial information about your sources of wealth and purpose of investment, tax information, including your tax file number (TFN), banking information and payment details.

When recruiting employees or appointing contractors, the IPG Group may collect and hold personal information such as:

The individual’s name, contact details, date of birth, citizenship, employment references, civil credit and criminal records, regulatory accreditation as may be required, driver’s licence information, education and employment history. Once appointed, we will also collect and hold TFNs, financial information relating to the appointment and banking details for payments.

Is sensitive personal information collected?

IPG FM and the IPG Group will not collect sensitive personal information on clients. Sensitive personal information is information about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information, genetic information, biometric information or biometric templates.

Why we collect, hold, use and disclose clients’ personal information?

We collect, hold, use and disclose personal information of clients for the purposes of providing financial products & services. This includes the establishment of your investment in our unregistered managed investment schemes, the ongoing administration and regular reporting on the performance in relation to this investment. Furthermore, it includes ongoing information about us and our activities, like new investment opportunities. You can contact our office if you do not wish to receive direct marketing from us.

We also need your personal information in order to comply with regulatory or legal requirements, including:

  • The Anti-Money Laundering & Counter-Terrorism Act 2006
  • The Corporations Act 2001
  • The Australian Securities and Investments Commission Act 2001
  • The Bankruptcy Act 1966
  • The Tax Laws Amendment (Implementation of the FATCA Agreement) Act 2014 the
  • Tax Laws Amendment (Implementation of the Common Reporting Standard) Act 2016; and applicable taxation law.
To whom might it be disclosed?

Generally, Group members, including IPG FM, will only disclose your personal information for the purposes of providing financial products and services to you. As Group members may outsource investment management and administrative services to IPGH under an Investment Management Deed, your personal information will be disclosed to related entities within the IPG Group. Personal information will also be disclosed to external third parties, where necessary to provide you with our financial products and services. These third parties may include government departments, regulatory authorities and law enforcement bodies, our auditors, insurers, banks, custodians, solicitors. It also extends to third-party IT services and administrators who assist us in the daily management of business operations, including managing client data. These

groups adhere to safeguarding personal information under the terms of a services agreement with us and/or operate in accordance with their privacy policies.

How is it collected?

For our wholesale investors, personal information is mainly collected through the application forms that you complete to access the financial products and services we provide. In addition, personal information may be provided to us via meetings, telephone, email and other correspondence. We may also receive personal information through third parties, such as financial advisors and security-related or identity verification services.

We may also collect information from you when you use our website or the IP Generation Investor Portal (Investor Portal).

Investor Portal

The IP Generation website contains a link to the Investor Portal, if you click on that link, you will be transferred to the Investor Portal which is also covered by this Policy.

The Investor Portal serves as a channel for investors to consider, invest and monitor the performance of investment opportunities created, managed or administered in relation to securities issued by IPG FM (and other Group members where applicable).

Some personal Information is automatically collected when you perform any action on, or interact with, any part of our Investor Portal or Services, including:

  • clickstream data, which is a record of how you navigate or click through our Investor Portal or Services; and
  • information obtained through the use of cookies, web beacons and similar storage technologies. Please refer to the section of this privacy policy entitled “Cookies and Tracking” for further information, including information on how you can disable these technologies.

Whenever you lodge a support query using our “Help” or “Contact us” features on the Investor Portal, we collect your name and email address, in order to be able to reply to you and provide the support or advice requested.

We control the access to the Investor Portal by only providing an activation email to authorised parties. Authorised parties will receive an email to access the Investor Portal and will be required to setup their password on first sign-in. Once a user has created a password, we won’t be able to see this information.

Users can add a second layer of security by enabling the 2-Factor Authentication (2FA) available in the Investor Portal. For your protection, we highly recommend all users to enable 2FA and maintain their login credentials confidential. If you become aware of any suspicious activity relating to your account or information, you must contact us immediately.

The use of Cookies

We may use temporary (session) cookies or permanent cookies when you access our website and our Investor Portal.

A cookie is a piece of information that our web server may send to your machine when you visit our website and Investor Portal. The cookie is stored on your device, but does not identify you or give us any information about your device.

The types of cookies we use may include (but are not limited to):

  • Session Cookies: These are temporary cookies that are erased when the user closes their web browser. They’re used to remember user activity within a single session, making it smoother to navigate the site.
  • Persistent Cookies: Also known as permanent or stored cookies, they remain on the user’s device even after the browser is closed. These cookies can be used to remember a user’s login information, preferences, and other persistent information for future visits.
  • First-Party Cookies: These cookies are set by the website the user is visiting, and they typically allow the website to keep track of the user’s activity during their visit.
  • Third-Party Cookies: These are set by domains other than the one the user is visiting, often by advertising and tracking services. They can be used to track a user’s activity across multiple websites and build up a profile of their interests.
  • Secure Cookies: These cookies can only be transmitted over an encrypted connection (i.e., HTTPS). They help to ensure that the user’s information is secure and prevent unauthorized access.
  • HTTP-Only Cookies: These cookies can’t be accessed by client-side scripts, which makes them more secure against potential cross-site scripting (XSS) attacks.
  • SameSite Cookies: These cookies help prevent Cross-Site Request Forgery (CSRF) attacks by allowing servers to assert that a particular cookie should not be sent along with cross-site requests.

With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. If you want to do this, refer to your browser instructions or help screen to learn more. If you reject the use of cookies, you will still be able to access our website and Investor Portal but please note that some of its functions may not work as well as they would if cookies were enabled.

Using cookies allows us to recognise your browser and track the web pages you have visited. We do not link this information back to your identity or other information that you have provided to us. We do not store any information that identifies you inside cookies. You can switch off cookies by adjusting the settings on your web browser.

Collection of Anonymous Information

We may track usage patterns on our website on an anonymous basis. Your identity cannot be reasonably ascertained from this information. When you visit our website, a web server will record your visit and specifically certain information, including information in relation to how you operate our website. For example, the pages you have visited, date and time of your visit, IP address of the computer. This information allows us to maintain and improve our website.

How is the information held?

We respect the personal information you have entrusted to us, and we have a responsibility to manage and protect that information. IPG FM and IPG Group members will take all reasonable steps to protect your personal information from misuse, interference and loss from unauthorised access. The protection of your personal information is part of our cyber security measures, which includes all the practices we have in place to protect computers, mobile devices and our network from malicious external attacks to the best of our ability. Cyber security is a continuing operational threat affecting all industries, including the financial services industry which is continuously subject to cyber risk, threats and challenges. Therefore, and in order to contribute to further mitigation of this risk, we have outsourced the management of our Information Technology to an external Information Technology (IT) specialised firm. This external company manages the Group’s IT environment on a daily basis and benefits from experience, knowledge and latest market insights to keep personal and corporate data safe.

Your personal information will be securely stored in an electronic environment, as we avoid storing hard copy information. With the exceptions detailed in this Privacy Statement, your information will only be available to employees of IPGH and to our service providers on a need-to-know basis in order to perform their obligations and duties.

We utilise the services of Caruso as the fund management software provider who may access your personal Information. Caruso is based in Auckland and Sydney, and uses Amazon Web Services (AWS) for cloud computing and storage services, predominantly in the US-west-2 (Oregon) region. Consequently, your personal information may be transferred to persons or entities located in these countries. We take reasonable steps to make sure the overseas recipient will not breach the APPs. You can access Caruso’s data security and third parties’ information here.

While we take reasonable steps to maintain secure internet connections, the supply of personal Information over the internet is at your own risk.

If you follow a link on our Investor Portal to another website, the owner of that website may have its own privacy policy that will apply to its use of your personal Information processed on that website. We suggest you review that website’s privacy policy before you provide access to your personal Information.

Changes in personal information

You should notify us asap if any of the information we hold about you, and which was provided to us by you or a person nominated by you, changes. It is important that we maintain true and correct records about you. Therefore, please inform us as soon as possible of any changes in relation to your personal and investment details. You can notify us of any changes by email to admin@ipgeneration.com.au. For security purposes, we will always verify and confirm requested changes by contacting you by phone.

How long will we keep personal information?

Your personal Information is kept as long as required for the purpose of providing financial services to you and as otherwise required by Australian law. In some instances we may receive information from you that is not required for or relevant to the financial service we provide to you. This information will be discarded as we only store relevant information.

For safety reasons we do not hold any information we may have received from you in a hard copy format. All hard copy documents we may have received, like signed application forms, ID documents and trust deeds, will be scanned, electronically stored and subsequently destroyed. If you would like us to return these hard copies to you, please contact our office.

What happens if personal information security is breached?

We implement corrective plans if we identify a breach of our security measures. For example, if your personal information has inadvertently been accessed by an unauthorised person or lost as a result of this unauthorised access. We will advise the Australian Information Commissioner and you if we assess the data breach is likely to cause you serious harm.

You can find out more information about the Privacy Act and the Australian Privacy Principles from the Australian Information Commissioner.

Notifiable Data Breaches

IPG FM is required to notify individuals and the Office of the Australian Information Commissioner about ‘eligible data breaches”. An eligible data breach occurs when the following criteria are met:

  • There has been an unauthorised access to, or disclosure of personal information held by us, and the breach is likely to result in serious harm to any of the individuals to whom the information relates, and:
  • We have been unable to prevent the likely risk of serious harm with remedial action.

We will conduct an assessment if it is not clear if a suspected data breach meets these criteria. The assessment will determine whether the breach is an ‘eligible data breach’ that triggers notification obligations.

How do you access your personal information and seek correction of it?

Should you wish to know what personal information the IPG Group holds on you, you may request to view this information by contacting our Privacy Officer:

Name: Harley Kras

Address: IPG Funds Management Pty Ltd

Mobile Number: 0402 511 888

Email: privacyofficer@ipgeneration.com.au

The Privacy Officer will promptly investigate your privacy enquiry and provide you with appropriate answers where required. You may also contact the Privacy Officer if you have any questions on our compliance with the Privacy Act 1988 (Cth).

In case you discover that any information held is outdated, incorrect or incomplete you should request to have the personal information corrected and IP Generation staff will update your records accordingly.

As outlined above, if your personal data changes during the life of the unregistered managed investment scheme, you need to contact IP Generation staff as soon as possible, so we can update your personal information you initially provided to us in the application form.

How can I complain about a breach of my privacy?

If you wish to make a complaint about our handling of your personal information you should contact the Privacy Officer using one of the above alternatives. If we cannot resolve your complaint, then you may raise your issue with the Office of the Australian Information Commissioner.

Additional information

Further information on privacy in Australia may be obtained by visiting the website of the Office of the Australian Information Commissioner (OAIC) at: http://www.oaic.gov.au/. We regularly review the OAIC website to keep informed of issues and developments in privacy law and changing legal obligations.